Privacy Policy

Last updated: November 24, 2023

REMOTIVELABS PRIVACY POLICY – Website & Platform

INTRODUCTION

RemotiveLabs AB, organized under the laws of Sweden, Company Registration No. 559202-0019, and its affiliates (collectively, “RL”), respect your privacy and are committed to protecting your personal data in full compliance with applicable law. This privacy policy explains how and why we collect and use the personal data of our clients, partners, suppliers, and visitors to our sites that we and/or our affiliates own and control (including remotivelabs.com), and how the law protects such personal data. Please refer to the Glossary to understand the meaning of some of the terms used in this privacy policy.

CONTENTS

  1. IMPORTANT INFORMATION AND WHO WE ARE
  1. THE DATA WE COLLECT ABOUT YOU
  1. HOW YOUR PERSONAL DATA IS COLLECTED
  1. HOW WE USE YOUR PERSONAL DATA
  1. DISCLOSURES OF YOUR PERSONAL DATA
  1. INTERNATIONAL TRANSFERS
  1. DATA SECURITY
  1. DATA RETENTION
  1. YOUR LEGAL RIGHTS
  1. GLOSSARY

CALIFORNIA PRIVACY RIGHTS

1. IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy explains how RL collects and processes your personal data through your use of this website, RL Solution and your interactions with RL staff. This policy only applies to the personal data described in section 2, in RL’s role as a data controller. This policy does not apply to any content, data or information processed, stored, or hosted by other persons or companies.

Our websites and our services are not intended for those persons under 18 years of age, and we do not knowingly collect data relating to or direct marketing at such persons. If you believe that we have collected information about a person under 18, please contact us per the contact details below, so that we may delete the information in question.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Data Controller

RL is the data controller (the entity which determines the purpose and means of processing personal data) with respect to the personal data described under this privacy policy (collectively referred to as “RL” “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact us as follows:

Email address:

privacy@remotivelabs.com

Postal address:

Remotive Labs AB
Stora Varvsgatan 6A, 4th floor

211 19 Malmö

Sweden
   

You have the right to make a complaint at any time to the supervisory authority for data protection issues in the country in which you reside. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

Changes to the Policy; Please Inform Us of Changes  

We keep our privacy policy under regular review and may modify this policy from time to time. If we make any changes to this Policy, we will post the amended terms and change the “Revised” date above.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third Party Links

This site may include links to third party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party sites, services, or applications, and are not responsible for their privacy statements.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (such as anonymous or deidentified data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, title, and position in your organization, as well as identifying numbers such as driver’s license or passport numbers.
  • Contact Data includes postal address, delivery address, email address, messaging and social network addresses, and telephone numbers.
  • Transaction Data includes payment details and information about transactions with and products and services you have purchased from us.
  • Generalized Relationship and Other Data includes details e.g. about your employer and other similar information that you elect to disclose to us, to the extent such details include personal data, as well as financial and business information disclosed in furtherance of our services or relationship.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from personal data but is not considered personal data or under applicable law as this data does not reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), nor do we collect any information about criminal convictions and offences.

Cookie Policy

We may collect Information using “cookies,” which are small files placed on your hard drive that may uniquely identify your browser and collect certain Information about you, and which are necessary to provide the functionality of our websites (such as for authentication) or, with your opt-in consent, help us analyze our web page flow, customize our services, measure promotional effectiveness, and promote trust and safety. Certain features are only available through the use of cookies. You are always free to decline cookies via your browser settings, although doing so may interfere with your use of the site. You may encounter cookies from third parties that we do not control. Please review our cookie policy here.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove or reject cookies, this may affect certain features of our sites. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org. Update or change your cookie consent.

Residents of Europe and UK

If you reside in the European Union, UK, Switzerland, Norway, Lichtenstein, or Iceland, and are protected by European data protection requirements, we will treat your personal data in compliance with applicable law including the General Data Protection Regulation (GDPR).

If you fail to provide personal data  

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a transaction you may have with us, but we will notify you if this is the case at the time.

3. HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods and sources to collect data from and about you including through:

  • Direct interactions. You may give us personal data by filling in forms or by corresponding with us by post, phone, email, live interaction, or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • request marketing to be sent to you;
    • engage with us in the provision and receipt of products and services;
    • enter a survey; or
    • give us feedback or contact us.
  1.  
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • technical data and analytics from providers based inside and outside the EU. 
    • contact and transactions data from providers of technical, payment and delivery services.
    • identity and contact data from publicly available sources such as social media networks.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data as the law allows. Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform a contract or engage in services we are about to start or have commenced.
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • where we need to comply with a legal obligation.

Purposes for which we will use your personal data  

We will process your personal data only where there is a lawful basis to do so, specifically:

  • to perform a contract or maintain a business or professional relationship with you or your employer, including:
    • using your information to deliver, or contact you regarding, products or services; and
    • exchanging information in connection with a contract or relationship between us.
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, including:
    • to deliver relevant content to you;
    • to make suggestions and recommendations to you about goods or services that may be of interest to you; and
    • to establish, exercise and/or defend our legal rights including in any legal proceedings.
  • to comply with a legal or regulatory obligation, including:
    • complying with any applicable regulatory requirements in terms of anti-money laundering rules;
    • undertaking conflict of interest checks; 
    • regulatory and contractually mandated audits; and
    • data protection rules.
  • where you have consented to the particular use of your data, including:
    • sending you marketing emails; and
    • taking part in surveys.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

We do not use personal data for the purpose of using automated decision making or profiling.

Promotional offers from us  

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive such marketing communications from us if you have requested information from us, have engaged in a professional or business relationship with us, or purchased goods or services from us, and you have not opted out of receiving that marketing. You may opt out of marketing at any time via contacting us.

Third-party marketing  

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Sales of personal data

We do not engage in the sale of personal data and will not do so unless we allow you a means of opting out, and except in connection with a merger, acquisition or sale of shares, business, or assets.  Opting out  

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of account management, product/service experiences, and other transactions.

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in section 4.

  • external third parties as set out in the Glossary.
  • third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or that we acquire or merge with. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.
  • our affiliated entities and our service providers, consultants, and other contractors in order to support or enhance our products, services and business operations, and to make available and consummate transactions and relationships. Such parties’ use and processing of personal data will be subject to security or confidentiality obligations consistent with this policy and applicable law, and pursuant to written contractual obligations consistent with this policy.
  • as required to comply with applicable law or lawful requests or process, or to enforce our terms and agreements, and to protect the rights, safety, and property of RL, our agents, employees, customers, and others.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • subject to the points below, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. 
  • where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. 
  • where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield or other mechanism which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach when we are legally required to do so.

8. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

9. YOUR LEGAL RIGHTS

You have rights under data protection laws in relation to your personal data. You have the right to:

a) request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

b) request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

c) request erasure or deletion of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

d) object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

e) request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • to establish the data’s accuracy.
  • where our use of the data is unlawful, but you do not want us to erase it.
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

f) request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

g) withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you or otherwise continue our relationship. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.What we may need from you  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 

Time limit to respond  

We try to respond to all legitimate requests within 45 days. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARYComply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We must consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Personal data or personal information means any information (either alone or in combination with other information we hold) that specifically identifies you as an individual, such as your name, address and physical location, account numbers, email addresses, and telephone numbers.

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

External third parties  

  • Service providers acting as data processors based inside and outside the EU, including in the United States, who provide IT and system administration services and secure cloud-based information services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, agents, auditors, and insurers based inside and outside the EU, including in the United Kingdom, who provide consultancy, banking, legal, insurance, travel, and accounting services.
  • Such companies may include other financial service providers such as brokerage firms, investment adviser firms, insurance companies, banks, leasing companies, fund managers and manufacturers, borrowers, lessees, sellers, buyers, and export, credit, and ratings agencies.
  • Please review a list of such third parties here.


CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with certain rights regarding our use of your personal information. 

A. “Do Not Track” under the California Online Privacy Protection Act. With the exception of Hubspot’s tracking code (see https://knowledge.hubspot.com/account-and-setup/topics#tracking-code),we are not aware of any processes for others collecting personal information about your activities on our websites over time and across third party websites, apps, or other online services, nor do we knowingly collect information about your activities over time across third party sites and services.

B. California’s “Shine the Light” law (Civil Code Section § 1798.83). This law permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to us as set forth in section 2.

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